PACIFIC HALIBUT ALLOCATION POLICY -- FACT SHEET Since its introduction in 2003, the Pacific halibut allocation policy has been upheld by successive Liberal and Conservative governments; four separate federal fisheries ministers have examined the facts and supported the policy. It seems prudent that the facts be considered before opinions are developed to ensure there is an informed, evidence-based discussion to support sound decision making and good public policy. The 88%:12% halibut allocations are not “arbitrary” or “inequitable” or based on “flawed data”. The halibut allocation policy was derived after a lengthy process that started in 2000 and included: an independently-facilitated series of meetings in 2000/01; and, the retention of Mr. Stephen Kelleher, Q.C. (who is now a B.C. Supreme Court Judge) in 2002 to provide independent advice to the Minister on initial allocation arrangements and how allocations may change over time. In 2003 the Minister of Fisheries and Oceans announced commercial and recreational shares of 88% and 12%, respectively, and called for both sectors to develop a suitable market-based mechanism to allow the transfer of allocation between the sectors. To allow for “growth”, the Minister provided the recreational sector with an allocation 33% larger than Justice Kelleher’s 9% recommendation. The methodology used to estimate recreational halibut catch data was peer-reviewed and approved by the DFO Pacific Scientific Advice Review Committee in 1999. Canada has used this methodology to report recreational harvests to the International Pacific Halibut Commission (IPHC) and meet its international obligations under the halibut treaty with the United States. There are conservation considerations -- Canada & the US are in a period of low halibut abundance. BC commercial fishermen have seen their allowable catch levels (and incomes) reduced by approximately 43% since 2006. Alaskan commercial fishermen have experienced similar declines. The recreational charter vessel fleet in south-east Alaska has been restricted to one (1) halibut per day, a limit has been placed on the number of charter vessels in Alaska and a proposal has been put forward that would allow Alaskan charter vessels to lease halibut quota from the commercial fleet. Washington State is managing its recreational halibut fishery with limits of one (1) halibut per day and two (2) in possession, with openings between 9 days and 49 days depending on the available harvest and location fished. Oregon uses similar measures but has an annual limit of six (6) halibut per year. In BC the recreational halibut fishery has limits of one (1) halibut per day and two (2) in possession (there is no annual limit), and the season was open for 260 days in 2010. First Nations bands and tribal councils make up a significant part of the commercial halibut fishery. Approximately 17% of the commercial halibut licences and individual quotas are designated to First Nations bands and tribal councils. Further, the Maa-nulth Treaty Final and Harvest Agreements both contain allocations of halibut for economic fisheries. These First Nations economic opportunities and treaty entitlements are part of the commercial 88% allocation. Anything that negatively impacts the commercial allocation would negatively impact First Nations economic opportunities and treaty entitlements. Not “gifted” - the vast majority of commercial fishermen have purchased their licences and quotas. Commercial halibut fishermen have been selling and purchasing licences since DFO first issued them in 1979, licences with quota attached since 1991 and licences and/or quotas since 1999. For example, -2- approximately 56% of the halibut quota was permanently transferred between licences during the 20002010 period alone. Commercial halibut fishermen have made significant investments in the fishery. The recreational fishing sector is not the Canadian public; very few Canadians fish recreationally. The number of Canadians holding BC tidal water recreational fishing licences has declined significantly over the past 15 years, both in absolute terms and as a percentage of the population. DFO has noted that across Canada fewer and fewer Canadians are going recreational fishing, due in part to changing lifestyles and other activities that compete for limited leisure time. The vast majority of Canadians do not recreationally fish but instead consume commercially-caught seafood in restaurants or at home. For most Canadians this is the only way they can get access to the fisheries resources they own. Commercial fishing provides food for Canada and the world. A survey conducted by Pollara for DFO found that Canadians thought private Canadian commercial fishers who currently have fishing licences should have higher priority than recreational fishers. According to DFO, only 10% of total recreational fishing effort is directed at halibut – few anglers fish for halibut. The vast majority (69%) of the recreational halibut catch is from the lodge & charter vessel sector. This is not a “mom & pop” sport fishery; it is driven by recreational fishing businesses. There is no evidence that the recreational halibut fishery is more valuable than the commercial. It is improper to use expenditures, revenues or input-output analysis to determine the relative economic value of commercial and recreational fisheries and economic impact analysis is not able to address the question of best economic use.1 To answer such questions a very specific and complex economic analysis must be undertaken; and the results would be highly uncertain and the analysis would have to be redone whenever inputs into the analysis change (e.g., fish prices, angler demand, energy prices). No such analysis has been undertaken for halibut. However, such an analysis was attempted by DFO and the Province of BC for chinook and coho salmon in 1996. Despite all the time and resources devoted to the project, the report concluded that the estimates were not good enough for allocation purposes and consideration should be given to moving to market-based transfers between commercial and recreational fishing interests as the means to allocate the salmon resource to its best use. The assertion that the 2011 recreational halibut season will close in June or July is unfounded. DFO has made no such statements to the recreational sector, and DFO Pacific Region has yet to meet with its own Sport Fishing Advisory Board to discuss the 2011 halibut season because the taxpayerfunded government advisory body refuses to provide advice. Further, a review of recent historic recreational halibut catch data clearly shows that at present harvest and effort levels, and current daily and possession limits, a June or July closure would not occur. “Allocation stabilization” and “fishery self-adjustment” are part of DFO’s national policy direction. The halibut allocation policy provides certainty and stability, and ensures allocation stabilization, for the recreational fishing sector, First Nations & commercial fishermen. The commercial halibut fishery “self adjusts”; it matches fleet size to the available harvest and prevailing economic conditions (e.g., fish prices, fuel and monitoring costs). As a result, not all licensed vessels fish each year. As noted by DFO, some harvesters have, over time, decided to leave the fishery and others have stayed and acquired additional quota to increase their harvest opportunities. 1. Edwards, S. An Economic Guide to Allocation of Fish Stocks between Commercial and Recreational Fisheries. National Marine Fisheries Service. 1990.
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